If you are a small maker and looking for the loophole here, this is it: "PPWR excludes an object where it is genuinely an integral part of the product, necessary to contain/support/preserve it throughout its lifetime and intended to remain with it."
De minimis and the previous packaging regulations were used as a tariff bypass by Chinese platforms like PDD and SHEIN, which led to their crackdown over the past 24 months [0][1]
Let me spell out the loophole: Just don't use packaging. Redesign your product so it comes in a sturdy container that makes it integral part of the product itself and completely side steps the obligations here.
